Right to counsel

While a state may have many statutes, court decisions, or court rules governing
appointment of counsel for a particular subject area, a "Key Development" is a
statute/decision/rule that prevails over the others (example: a state high court
decision finding a categorical right to counsel in guardianships cases takes
precedence over a statute saying appointment in guardianship cases is
discretionary).

Litigation, Civil Contempt in Family Court

The Wisconsin Supreme Court has held that individuals are entitled to appointed counsel in a remedial contempt proceeding “where the threat to liberty is real,” and when the state is a party to the action. State v. Pultz, 556 N.W.2d 708, 715 (Wis. 1996) (indigent individual entitled to appointed counsel “when an arm of government brings a motion for a remedial contempt hearing against an individual, and that person's liberty is threatened”). Pultz confirmed its pre-Lassiter holding from Ferris v. State, 249 N.W.2d 789, 791 (Wis. 1977) (finding right to counsel in contempt proceeding and holding that, “absent a knowing and intelligent waiver of counsel,” defendant must be advised of right to counsel prior to contempt hearing), and rejected the state’s contention that Lassiter had negated Ferris as well as the state’s invitation to adopt a case-by-case test, noting that “an indigent defendant may not even ‘have the keys’ if he is not presently able to comply with the forfeiture requirement.” The court did not state which constitution it was addressing, although it said the litigant was arguing that “under decisions of both the United States Supreme Court and this court, indigent civil litigants are entitled to the assistance of appointed counsel when they face the prospect of incarceration.”

Note that the holding in Pultz was specifically premised on “an arm of government bring[ing] a motion for remedial contempt,” which is distinguishable from cases involving civil contempt proceedings related to matters initiated by private litigants. See, e.g., Turner v. Rogers, 564 U.S. 431, 448 (2011) (Fourteenth Amendment “does not automatically require the provision of counsel at civil contempt proceedings to an indigent individual subject to a child support order, even if that individual faces incarceration,” particularly where “the opposing parent … is not represented by counsel and the State provides alternative procedural safeguards[.]”) (emphasis in original).

If "yes",
the established right to counsel or
discretionary appointment of counsel
is
limited
in some way, including any of: the only authority
is a
lower/intermediate court decision or a city council,
not a high court or state legislature; there
has been
a subsequent case that
has
cast doubt; a statute
is
ambiguous; or the right or discretionary appointment
is not
for all types of individuals or proceedings
within that category.